GDPR Notice
Purpose
Washington State University Extension and the College of Agricultural, Human, and Natural Resource Sciences (referred afterwards as “we,” “us,” and “our”) is committed to respecting and protecting the privacy rights of persons (from now on referred to as “you” and “your”). This commitment is in compliance with the EU General Protection Regulation (from now on referred to as (“the GDPR”).
Does This GDPR Privacy Notice Apply to Me?
This policy applies to you if all of the following applies:
- You are a “Person” or “Data Subject” as defined by the GDPR—meaning a natural person and not a corporation, partnership, or legal entity within the meaning of the GDPR—and you are physically present in the EU.
- We process—meaning collect, record, organize, structure, store, adapt, alter, retrieve, consult, use, disclose by transmission, disseminate, make available, align, combine, restrict, erase, or destroy—your Personal Information—meaning any information relating to an identified or identifiable Person through direct or indirect ways;
- Your Personal Information is provided to us while you are in the EU (not earlier or later when you are outside the EU); and
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Your Personal Information is provided to us when:
- We are offering goods or services to you in the EU; or
- We are monitoring your behavior in the EU.
Please note that information pertaining to current, former, or prospective employment with WSU Extension and CAHNRS in the United States is not considered “Personal Information” and is excluded from this GDPR Privacy Notice.
What Personal Information Do We Process
Our application's and websites process the following data
- Names
- Addresses
- Telephone numbers
- Email addresses
- Identification numbers including but not limited to social security numbers and driver’s license numbers
- WSU identification numbers
- Personal identification numbers
- Usernames
- Passwords
- Demographic information
- Education history and transcripts
- Exam scores
- Personal references
- Emergency contact information
- Financial information including but not limited to credit and debit card numbers and tax information
- Transaction history
- Business information
- Passport and visa information
- Work history
- Medical history
- Donation history
- Insurance information
- Military service
- IP addresses
- Location information
- Device information
- Metadata
- Education records including but not limited to coursework, correspondence, evaluations, and other records, and files maintained by us as part of the educational process
- Any requests for accommodations or leave
- Other information to support our mission and legitimate purposes as a Washington State public University
Why We Process Your Personal Information
We process your Personal Information for a variety of reasons depending on your role and the activities you engage in. This includes managing web application accounts, authentication and authorization, troubleshooting, support, and developing features and processes based on utilization trends. Please see Appendix A for what types of Personal Information we may process that relates to you.
What Are Our Legal Bases For Processing Your Information?
We process your personal information as permitted by the GDPR, including under the following legal bases:
- To Perform a Contract: Our processing of your Personal Information is necessary for us to perform a contract or take steps at your request prior to our provision of educational or Extension services;
- Legitimate Interest: Our processing of your Personal Information is necessary for our legitimate interest in providing you services and assistance, while helping us provide educational and Extension services related to programs and activities as part of our core mission as a land grant institution;
- Vital Interest: Our processing of your personal data is to protect an interest that is essential to your life or the life of someone else;
- Legal Obligations: the processing is necessary to comply with State, Federal, EU or other applicable law
Special Categories of Data. In general, we process special categories of data in order to fulfill a substantial public interest in providing educational services and related programs and activities to students, staff, faculty and the public. At times, the processing might be to protect an interest that is essential to your life or the life of someone else.
If we do not have another legal basis for processing your special category Personal Information or criminal conviction Personal Information, we will ask for your consent.
Consent. In very limited circumstances, usually only in instances where we are collecting special categories of Personal Information, we may rely upon the legal basis of consent. If we require your consent for any specific use of your Personal Information, we will collect it at the appropriate time. Your consent (and right to withdraw consent) may be specifically limited to only the particular information for which consent is needed.
Please note that by providing us with special categories of Personal Information which are unsolicited by us (such as in inquiries, feedback, etc.), you have consented to give us that information and you understand that we will treat that information the same as we treat other information that we gather in a similar manner.
How Do We Receive Your Personal Information
From you, the Data Subject
We may receive Personal Information when you visit our websites, register for not-for-credit courses and programs, apply to volunteer, attend CAHNRS events, or otherwise interact with CAHNRS.
From Third Parties
We may receive your Personal Information when other individuals or organizations provide it to us. Some examples are given below:
For members of the public: Some examples of how we may receive your Personal Information from other individuals or organizations include from State or Federal Agencies under a data sharing agreement or other institutions adminstering outreach programs as part of collaborative processes.
For volunteer applicants or staff and faculty: Some examples of how we may receive your Personal Information from other individuals or organizations include from previous employers, educational or vocational programs you have attended, references, or companies or individuals with whom we have contracted to perform services in relation to your employment or our provision of educational services and programs.
Who Processes Your Personal Information
Our Personnel
We may share your Personal Information internally with staff, faculty, researchers, Extension Specialists, or other agents of CAHNRS who have been authorized to receive your Personal Information.
Our Related Organizations
We may share your Personal Information with our related organization such as corporations, owned by WSU (e.g. Washington State University Foundation, etc.).
Third Parties
We may share your Personal Information with third parties, such as: U.S. and foreign government entities to fulfill statutory or regulatory obligations (e.g., visa processing); other entities to facilitate access to grant funding sources; partner institutions or companies to facilitate training or educational activities; and other vendors to provide services related to your affiliation with us. Please note that we may provide anonymized data developed from Personal Information to third parties, such as government entities and research collaborators, and that such anonymized data is outside the scope of this GDPR Privacy Notice.
Existence of Automated Individual Decision-Making
We do not typically use automated individual decision-making tools related to providing services and experiences related to the provision of educational services and related programs and activities. In general, you will not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless the decision is necessary for entering into or performing a contract or unless you explicitly consent.Retention, rights, and contact - See Appendix B.
Updates to GDPR Notice
We may update this notice from time to time. Any changes will become effective upon posting of the revised notice. Please note:
- This policy is in addition to the WSU Privacy Policy.
- Nothing in this Notice is intended by us to waive sovereign immunity or any other defenses or immunities afforded by any or all U.S. federal law, Washington state law, and EU law.